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PRESIDIO, INC.

WHISTLEBLOWER POLICY

(Adopted on February 24, 2017)

This policy outlines the procedures that the Audit Committee (the “Audit Committee”)
of the Board of Directors (the “Board”) of Presidio, Inc., a Delaware corporation (together with
its direct and indirect subsidiaries, the “Company”), has established with respect to the receipt,
treatment and retention of complaints received by the Company regarding (1) accounting, inter-
nal accounting controls or auditing matters, including the confidential, anonymous submission
by employees of concerns regarding questionable accounting or auditing matters, (2) the report-
ing of fraudulent financial information of or by the Company or (3) violations or potential viola-
tions of the federal securities laws, including any rules and regulations thereunder, the Compa-
ny’s Code of Business Conduct and Ethics, or the Civil False Claims Act, the U.S. Foreign Cor-
rupt Practices Act of 1977, as amended, the U.K. Bribery Act of 2010 or similar laws (the
“Fraud/Anti-Corruption Laws”) (collectively, “Complaints”).

The Company is committed to maintaining high standards of financial integrity, and the
Audit Committee takes very seriously all Complaints and concerns regarding accounting, inter-
nal accounting controls, auditing and other legal matters. The Company’s financial information
guides the decisions of the Board and management and is relied upon by the Company’s stock-
holders, employees and business partners. The Company’s policies and practices have been de-
veloped to maintain the highest business, legal and ethical standards. For these reasons, the
Company must maintain a workplace environment where all of the employees of the Company
(the “Employees”) who reasonably believe that they are aware of any Complaints can raise these
concerns free of any harassment, discrimination or retaliation. It is the Company’s policy to en-
courage Employees to report those concerns as soon as possible after discovery. The Company
strives to encourage open communication so that such concerns can be raised without fear of re-
taliation in any manner.

Accordingly, the Audit Committee has established the following procedures for:

• The receipt, retention and treatment of Complaints regarding accounting, internal ac-
counting controls or auditing matters; and

• The submission by Employees (confidentially and anonymously, if they wish, in the


United States, and in any other jurisdiction to the fullest extent legally permitted in such
other jurisdiction), and the appropriate treatment, of concerns regarding accounting or
auditing matters they believe to be questionable or violations of the Company’s Code of
Business Conduct and Ethics, the U.S. federal securities laws or other state and federal
laws, or Anti-Corruption Laws.

The Audit Committee is committed to continuously reviewing and updating its policies
and procedures. The Company may modify this policy at any time without notice. Modification
may be necessary to, among other reasons, maintain compliance with applicable laws, rules and
regulations and/or to accommodate organizational changes.

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A. Matters that Must be Reported

Employees must immediately report and submit Complaints for which there is actual or
suspected:

• Intentional error, fraud or gross negligence in the preparation, review or audit of any of
the Company’s financial statements;

• Intentional error, fraud or gross negligence in the recording of transactions of the Com-
pany;

• Intentional noncompliance with the Company’s internal and reporting controls;

• Significant deficiencies in the Company’s internal and reporting controls;

• Misrepresentation or false statement to or by a senior officer or accountant regarding a


matter contained in the financial records, financial reports or audit reports of the Compa-
ny;

• Deviation from full and fair reporting of the Company’s financial condition;

• Violations of U.S. Securities and Exchange Commission (the “SEC”) rules and regula-
tions that are related to accounting, internal accounting controls and auditing matters;

• Fraud against investors, securities fraud, mail or wire fraud, bank fraud or fraudulent
statements to management, outside auditors, the SEC or members of the investing public;

• Violations of the Company’s Insider Trading Policy, the U.S. federal securities laws or
the Fraud/Anti-Corruption Laws; or

• Violations of the Company’s Code of Business Conduct and Ethics or other applicable
laws.

Failure to report these matters may result in disciplinary action, up to, and including, ter-
mination. Timeliness is critical because, as with all investigations, evidential matter may deteri-
orate, disappear or otherwise become harder to discover or less useful as time passes. Employ-
ees should provide the subject matter of his or her Complaint and the practices that are alleged to
constitute an improper accounting, internal accounting control or auditing matter, or a violation
of the federal or state securities laws or the Anti-Corruption Laws and as much detail as possible
regarding dates, times, places, names of people involved in any way, actions or inactions, state-
ments made or the identity of other evidential matter.

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B. Procedures for Receiving Complaints

Non-Employees must submit Complaints by mail to:

Presidio, Inc.
Attn: Compliance Officer
One Penn Plaza, Suite 2832
New York City, NY 10119

Employees may submit Complaints to the Company (confidentially and anonymously, if


they wish, in the United States, and in any other jurisdiction to the fullest extent legally permitted
in such other jurisdiction) in one or more of the following ways:

• The complaining party may place a phone call to the “Employee Reporting Line,” an
offsite, third-party service provider voicemail account. The Employee Reporting
Line may be reached at (877) 441-1681, or, for Employees outside the United States,
at the phone numbers listed at http://www.openboard.info/PSDO, and calls may be
made anonymously;

• The complaining party may register his or her Complaint, via a third-party service
provider website at http://www.openboard.info/PSDO (the “Employee Reporting
Website”) by following the directions on such website;

• The complaining party may submit a confidential memorandum to the Chairperson,


any other member of the Audit Committee or to the Company’s Compliance Officer
identified in the Company’s Code of Business Conduct and Ethics (the “Compliance
Officer”) via PSDO@openboard.info;

• Via regular mail as set forth above; or

• Via electronic mail to the Compliance Officer.

All Employees will be instructed through postings on the Company’s external and inter-
nal websites and the Company’s Code of Business Conduct and Ethics that any and all Com-
plaints may be made anonymously and in a confidential manner in accordance with one or more
of the procedures set forth above. Employees will also be notified that, if they do not feel com-
fortable submitting a Complaint in accordance with these procedures or if they feel that a previ-
ously submitted Complaint was not adequately addressed, they may contact the Chairperson or
any other member of the Audit Committee directly by telephone or mail. The Company will
provide notice on a current basis through postings on the Company’s external and internal web-
sites, the Company’s Code of Business Conduct and Ethics and/or such other manner as is de-
termined by the Audit Committee from time to time of the names, phone numbers and addresses
of the designated recipients to whom Complaints may be submitted.

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Except for Complaints sent directly to the Audit Committee, all Complaints will be for-
warded to the Legal Department for coordination of their treatment as set forth below. Any
Complaint received by the Audit Committee, the Compliance Officer or the Employee Reporting
Website in accordance with the procedures set forth above will be forwarded in a confidential
manner to the Chairperson of the Audit Committee as soon as reasonably practicable following
receipt of such Complaint. In addition, management will be informed that any Complaint re-
ceived outside of these procedures should likewise be forwarded in a confidential manner to the
Chairperson of the Audit Committee as soon as reasonably practicable following receipt of such
Complaint.

To ensure that these Complaint procedures are not inadvertently or improperly screening
out Complaints that should be viewed by the Audit Committee, the Compliance Officer will be
charged with preparing and submitting to the Chairperson of the Audit Committee, prior to each
regularly scheduled meeting of the Audit Committee, a table or other report detailing the time,
date, nature and disposition of each Complaint received by the Compliance Officer and/or the
Employee Reporting Website since the date of the prior report. The table or other report will be
reviewed by the Audit Committee at its next regularly-scheduled meeting.

C. Procedures for Treating Complaints

All accounting and auditing related Complaints received shall be entered on an accounting
and auditing matters log, which shall include, among other things: (a) information regarding the
date the Complaint was received, (b) a description of the Complaint, (c) the submitter (if provid-
ed) and (d) the status and disposition of an investigation of the Complaint. Receipt of the Com-
plaint will be acknowledged to the sender, within a reasonable period following receipt, if appro-
priate information for response is supplied. Non-accounting or non-auditing Complaints shall be
logged separately and will be forwarded to the appropriate person or department for investigation
(e.g., Human Resources), unless the Compliance Officer or the Chairperson of the Audit Com-
mittee deems other treatment is necessary (e.g., such Complaint involves a finance employee or
an executive officer).

With respect to Complaints not initially directed to the Audit Committee, the Compliance
Officer will report immediately to the Audit Committee: (i) matters related to violations or po-
tential violations of the Anti-Corruption Laws or similar laws, (ii) matters associated with the
Company’s revenue recognition policies or which involve accounting, internal accounting con-
trols and auditing matters, (iii) matters related to the Company’s executive officers and (iv) such
other matters as the Compliance Officer deems significant. Following receipt of a Complaint,
the Audit Committee shall direct and oversee an investigation of the Complaint. The Audit
Committee may also delegate the oversight and/or investigation of such Complaints to the ap-
propriate members of the Company’s management.

All other Complaints regarding accounting or auditing matters shall be reviewed under the
direction and oversight of the Compliance Officer, who will involve such other parties (e.g.,
members of the Company’s finance department or outside advisors) as deemed appropriate. The
Compliance Officer shall provide the Audit Committee with a quarterly report of all accounting
or auditing Complaints received and an update of pending investigations. The Audit Committee

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may request special treatment for any Complaint and may assume the direction and oversight of
an investigation of any such Complaint.

Confidentiality will be maintained to the fullest extent possible, consistent with the need
to conduct an adequate review. Access to reports and records of Complaints may be granted to
regulatory agencies and other parties at the discretion of the Audit Committee. Documents that
are covered by the attorney-client communication and/or work-product privileges should not be
disclosed unless the Compliance Officer has consented in writing to a waiver of privilege.

In all cases, prompt and appropriate corrective action shall be taken as determined by the
Audit Committee. An Employee may be subject to disciplinary action, which may include the
termination of his or her employment, if the Employee fails to cooperate in an investigation or
deliberately provides false or misleading information during an investigation. The specific ac-
tion that will be taken in response to a report will depend on the nature and gravity of the con-
duct or circumstances reported and the quality of the information provided. Where questionable
accounting, internal accounting controls or auditing matters or the reporting of fraudulent finan-
cial information is verified, corrective action will be taken and, if appropriate, the persons re-
sponsible will be disciplined.

The Compliance Officer or Audit Committee will report the results of any investigation
regarding a Complaint, including any corrective actions taken, to the person making the Com-
plaint, if appropriate information for response was supplied, maintaining the anonymity of the
person making the Complaint to the fullest extent possible.

D. Procedures for Retaining Records Regarding Complaints

The Compliance Officer shall retain written Complaints, the accounting and auditing
matters log and all related documentation as required under applicable law or any document re-
tention policy.

E. Protection for Whistleblowers

At no time will there be any reprisal, retribution or retaliation by the Company or at its
direction in any way against any Employee for making a reasonable Complaint, in good faith, or
against any person who assists in any investigation or process with respect to such a Complaint
or related concern. Employees who believe they have been subjected to any discrimination, re-
taliation or harassment for having submitted a Complaint, or having participated in an investiga-
tion a Complaint, should immediately report the concern to the Compliance Officer, the Legal
Department, the Chairperson of the Audit Committee or any of their supervisors. Any such re-
port that discrimination, retaliation or harassment has occurred will be promptly and thoroughly
investigated. If such report is substantiated, appropriate disciplinary action will be taken, up to
and including termination of employment for those individuals that engaged in the harassment or
retaliation.

F. Disciplinary Action

Nothing in these procedures shall limit the Company or the Board or a committee or de-
signee thereof in taking such disciplinary or other action under the Company’s Code of Business

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Conduct and Ethics or other applicable policies of the Company as may be appropriate with re-
spect to any matter that is the subject of a Complaint.

G. Periodic Review and Modification of the Policy

The Audit Committee will review the policy and consider changes to the policy periodi-
cally. The Company may modify this policy at any time without notice. Modification may be
necessary, among other reasons, to maintain compliance with applicable laws, rules and regula-
tions and to accommodate organizational changes.

The Audit Committee shall provide reports to the Board periodically, and at least annual-
ly, regarding all significant Complaints and the results of any investigation regarding a Com-
plaint, including any corrective actions taken.

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